a1a
tanding any time limits
in the domestic law of the Co’
tracting States.
3 — The competem
autliorities ofthe Contracting
Sta-.
tes shal 1 endeavour to resolve by
mutual agremet any
difficulties or doubts arising as
to the interpretation
or
application ofthe Convention.
4 - The cornpetent authorties
ofthe Contracting
Sia
tes may eornmunicate witheach
other.directly, inc.iuding
through a joint commission
consisting of themselves or
their representatives, for
the purposç ofreaching an agre
ement in the ense ofthe preceding paragraphs.
Article.26
Exchnge or informatioi
1 — The competent
authorities ofthe Contractirig States
shall exchange such information as
is foreseeably relevant
for canying out the provisibns
ofthis Convention or to the
administration or enforcement ofthe
dornestic laws concer
ning taxes ofevery kind
and description imposed
on behaif
ofthe Contracting States,
or oftheir politicai or administ;a
tive subdivisions or local
authorities, insofar as the taxation
thereunder is not contrary to
the Convention. The exchange
of infomiation is r’ot restricted
by articles 1 and
2.
2 Any information
received under paragraph
1 by
a Contracting State shall be
treated as secret in the
sane
manner as information
obtained under the domestic
laws
of.that State and shall be
disclosed oniy to persorls
or
authorities (including
courts and administrative
bodies)
concerried withthe assessn’ent
or coilection of the enfor
cemenT or prosecution
iii respect of, the deterrninationof
appeals in relation to the
taxes referred to in
paragraph 1,
or the oversight ofthe above.
Such persons or authorities
shall use the information only
for suci’ purposes. They
may discIosethe
information in public court
proceedings
or injudicial decisions.
3 —- In no case shall
the provisions ofparagraphs
1 and
2 be construed so as to impose
on a Contracting
Stare the
obligation:
a) to carry out administrative
measures at variance
with
the laws andadministrative
practice ofthat or oftheóthër
Contracting State;
b) to supply information
which is not obtainable
under
the laws or in the
normal course of the administration
of
that õr of the other Coïitracting
State;
c) to suppiy irformation
which would disclose any
trade
business industrial commercial
or professional secret or
trade process, or information
the disclosüre ofwhich would
be contrary td úblic pólicy (ordrepublic).
4 — Ifinfonration is requested
bv a Contracting Scate
jn accordance with this
article, the other Contractirig
State
shali use its information
gathering measures to obtàiri
the
reqüested inforrnatiõn,
eve though that other State
.may
nót rieed such information
for its own tax púrposes. The
o&igation contained in
the preceaing sentence
is ubiect
to tht linlitations ofparagraph
3 but in no case shall
such
limitations be construed to
permit a Cohtracting State to
DAR II Série A / 53

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